IR 05000382/1993005

Insp Rept 50-382/93-05 on 930125-29.No Violations Noted. Major Areas Inspected:Radiation Protection Activities Including Refueling Outage Support,Audits & Appraisals, Program Changes & Training & Qualifications

ML20138D706
Person / Time
Site:	Waterford
Issue date:	02/16/1993
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20138D688	List: IR 05000382/1993005 ML20138D683
References
50-382-93-05, 50-382-93-5, NUDOCS 9302230044
Download: ML20138D706 (10)

Text

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report: 50-382/93-05 Operating License: NPF-38 Licensee: Entergy Operations, In P.O. Box 8 Killona, Louisiana 70066 Facility Name: Waterford Steam Electric Station, Unit-3 Inspection At: Taft, Louisiana inspection Conducted: January 25-29, 1993 Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Facilities inspection Programs Section Approved: CU L 144 G4/

B. Murray Chief, Facilit es inspection Date programs Section -

Inspection Summar_y i

Areas inspected _: Routine. announced inspection of radiation protection o activities including refueling outage' support, audits and appraisals, program changes, training and qualifications, exposure controls, and the program to maintain occupational exposures as low as reasonably achievable (ALARA).

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Results:

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e Sufficient time was allowed prior to the commencement of the refueling l outage for radiation protection workers to perform meaningful' reviews of proposed work packages and to incorporate dose saving measures (Section 2.1).

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= Qualified senior contract. radiation protection technicians were used to

supplement the permanent staff during the refueling outage L (Section 2.2).

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' . Total parson-rem exposure received during the refueling outage was below i the ALARA goal (Section 2.3).

i = Quality assurance surveillances were good program assessment tools for j management (Section 3.1).

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9302230044 930217 PDR -ADOCK 05000302 0 'PDR-1:

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• The corporate office provided good support to the onsite radiation ,

protection program (Section 3.1). >

e A high quality system of occurrence reporting was in use (Section 3.1).

e The timeliness of the radiation protection department's response to quality notices had improved, but some responses were made after the due date (Section 3.1).

e New senior radiation protection technicians met qualification _ -i requirements (Section3.3).

. The licensee promoted the professional development of radf ation protection technicians (Section 3.3).

. Areas within the radiological controlled area were properly posted-and controlled (Section 3.4).

. Radiation protection pe sonnel provided excellent coverage for power entries into the containment building (Section 3.4).

• Good support was provided for the ALARA program. ALARA committee meetings were well attended by the plant manager and representatives' of  ;

all work groups (Section 3.5).

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• The licensee's actual total exposure was below its goal for 1992 and was well beJow the national average for pressurized water reactors (Section 3.6).

Summar_v of Insoection 'Findinas:

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Violation 382/9210-01 was closed (Section 4.1).

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Violation 382/9221-01 was closed (Section 4.2). -

. Licensee Event Report 91-006 was closed (Section 5). i Attachment:

• Attachment - Persons Contacted and Exit Meeting

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-3-DETAILS 1 PLANT STATUS During this inspection, the plant was operating at 100 percent powe OCCUPATIONAL EXPOSURE DURING EXTENDED OUTAGES (83729)

The licensee's program was inspected to determine compliance with Technical 5)ecification 6.8 and the requirements of 10 CFR Part 20, and agreement with tie commitments of Chapter 12 of the Final Safety Analysis Repor .1 Plannina and Preparation The inspector discussed the planning for the 1992 refueling outage (Refuel-5)

with radiation protection representatives and determined that the work packages and radiation work permits for the outage were submitted far enough in advance of the work to allow radiation protection personnel sufficient time to review them and initiate dose saving measures. The inspector reviewed a list of the high dose jobs and selected associnted work packages. The inspector determined that the work packages contained an ALARA checklist, man-hour estimates, area radiation survey results, radiation work permits, prejob briefing guidance, and post job reviews. tessons learned from the licensee's job history files had been incorporated properly into the job plannin The inspector-compared attendance lists of prejob briefings with personnel entry lists generated by the access control computer and verified that individuals received prejob briefings as required by certain radiation work permit The inspector also reviewed the number of entries into containment by radiation protection managers ~and supervisors and determined that an adequate number of entries were made by most supervisors to maintain a current knowledge of work in progress. The inspector noted, however, that the radiation protection superintendent did not enter containment to observe working condition .2 Trainino and Qualifications The inspector reviewed selected resumes of senior contract radiation protection technicians hired to support outage activities and determined that they met qualification requirements. The licensee had established written guidance for the evaluation of previous work experience of the contract radiation protection technicians, in preparation for outage work such as for the installation of steam generator nozzle dams, the licensee conducted mock-up training to acquaint workers with possible complications or time consuming activities in higher dose area _ ,- . - -

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-4-2.3 Maintainino Occupational Exposure AtARA The licensee's goal for the outage was 210 person-rem. Even though the scope of the outage work was increased to include more testing on the steam generators, the resultant cumulative exposure was approximately 178 person-re .

2.4 Conclusions The licensee defined the scope of the refueling outage work early enough to allow the radiation protection department to perform meaningful reviews of proposed work packages and to incorporate dose saving measures into the work instruction Qualified senior contract radiation protection technicians were selected to supplement the permanent staff during the refueling outag Total person-rem exposure received during the refueling outage was below the ALARA goa OCCUPATIONAL EXPOSURE CONTROL (83750)

The radiation protection program's support of the 1992 refueling outage was reviewed to determine compliance with Technical Specification 6.8 and the requirements of 10 CFR Part 20, and agreement with the commitments of Chapter 12 of the Final Safety Analysis Report 3.1 Audits and Appraisals The licensee had not performed audits related to the areas reviewed during this inspection, since those documented in NRC Inspection Report 50-382/92-2 However, the inspector reviewed selected quality assurance surveillances and noted that the surveillances covered a wide range of activities and were performed by an individual with technical expertise in radiation protection activities. Some surveillances identified activities which were not in compliance with operating procedures and many included observations for program improvement. Overall, the surveillances provided a good assessment of the performance of the radiation protection grou The inspector interviewed a representative of the corporate office to determine the type of support provided to the onsite radiation protection program by that office. The corporate office performs assessments, as requested, of different aspects of the radiation protection program, such as recent assessment of the whole-body counting program. The corporate office plans, for the fourth quarter of 1993, an assessment of the licensee's readiness to implement the new 10 CFR Part 20 requirements. Additionally, the corporate office maintains a knowledge of industry events and regulatory changes and develops company-wide contracts with vendors._ The corporate individual with these responsibilities was the former onsite radiation protection superintenden .. , .. _. - _ _ _ _ _ . . _ - . - . -

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-5- 1 The radiation protection superintendent required the radiation protection l supervisors to tour the radiological controlled area on a weekly, rotational l basis and report their observations of procedure compliance and needed _

improvement. The inspector reviewed select examples of the supervisors'

reports and determined that they constituted a useful management too The inspector reviewed the licensee's occurrence reporting system and noted that plant-wide methods were used which included the radiation protection program. The first level in the occurrence reporting system was the precursor

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trending program. The system had a low reporting threshold and was available to all personnel wishing to identify a situation or problem. The' occurrence ,

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program was coordinated by the reliability engineering group which trended the information and provided it to the program managers for use in identifying recurrent problem areas. Judging from the latest information reviewed by the inspector (third quarter 1992), the precursor trending program was frequently used by plant personnel. There were 334 precursor trending program cards submitted which resulted in the identification of 75 deficiencies. Of these, three were in the area of radiation protectio The next level of occurrence reporting was the quality notice. The-inspector reviewed quality notices involving the radiation protection program and noted that radiation protection personnel identified the root causes of the occurrences and performed corrective actions. The-timeliness of the responses

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had improved since the review documented in NRC Inspection Report 50-382/92-10; however, some of the responses, such as for QA-92-122 and QA-92-136, were submitted by the radiation protection department 2 to 4 days after the due.date. Quality assurance personnel stated that the responses from the radiation protection department were typically among the most promp .2 Channes

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A corporate-wide reorganization occurred in 1992, out these corporate changes had only minimal impact on the radiation protection department. The changes in the radiation protection department involved the elimination of one level of supervision and the reassignment of two of the three ALARA personnel to other group .3 Training and Qualifications of New Personnel The inspector reviewed the resumes of senior radiation protection technicians hired since the previous inspection of this area and determined that they met the qualification requirement The inspector interviewed the technical training supervisor and_ determined that two instructors were assigned to general employee training, and two were assigned to health physics _ technical training. (One of the health physics instructor's positions was vacant.) 'The inspector reviewed the qualifications of the instructors and determined that they had previous health physics or industry experience which was appropriate for their positions. The programs remained largely unchanged since their last review, documented in NRC Inspection Report 50-382/92-1 .

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-6-The technical training supervisor stated that the instructors did not have to work overtime to handle the teaching requirement brought about by the recent refueling outag The number of radiation protection personnel registered .(certified) by the National Registry of Radiation Protection Technologists increased to 17 (of approximately 40, excluding radwaste personnel). The licensee offered a training course to prepare the technicians for the examination and paid the fee of those individuals passing the examinatio .4 Exposure Control ,

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By direct observations during tours of the radiological controlled area,'the inspector determined that radiation areas and high radiation areas were prcperly posted. Locked high radiation areas were controlled as require Contaminated areas were properly demarcated and labele The-inspector:made independent measurements but did not identify additional areas requiring labeling or control. Housekeeping within the radiological controlled area was generally good. A sufficient number of operable frisking stations and personnel contamination monitors were noted by the inspector during the tour :

The inspector reviewed activities involved with a full-power entry into the containment building by workers on January 26, 1993. The inspector determined that the radiation protection superintendent, who was not on site at the time of the inspection, had prepared a written delegation of power. The entry wa . authorized, as required by Procedure HP-001-213. " Control of Reactor Containment Building Power Entries," by the superintendent's designe The inspector. confirmed that the radiation protection personnel took air samples, determined the oxygen content, reviewed radiation measurements, and completed all items on the power entry checklist included in the governing procedure prior to personnel entr .5 Ma.intainina Occupational Exoosure ALARA The inspector attended the quarterly ALARA committee meeting and noted that it -

was well attended by the various groups represented. - A review of the minutes of past meeting confirmed that attendance was-consistently. good by all group The plant general manager took an active part in the meeting. Communications were open, and individuals appeared free to express their opinions on the various subject As stated in Section 3.2,-the two technicians reporting to the ALARA: -. ..

coordinator were reassigned. Radiation protection representations stated that the duties performed by these individuals, such as the preparation of

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radiation work permits, would be spread among more personnel, enlarging the pool of expertis The licensee's ALARA suggestion program received 20 suggestions in 1992. .The inspector confirmed that the suggestions were evaluated and acted upon in a timely manne + ' . . _ - , . < , - , , , ,v - , -

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The licensee's exposure goals and results for 1992 as presented at the ALARA committee meeting are shown below. (The totals include pocket ion chamber results for the final quarter 1992 and may differ slightly from thermoluminescent dosimeter results.)

Goal * Actual *

Regular Operations 30 33 Refueling Outage 210 178 Total 240 210

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3.6 Conclusions Quality assurance surveillances were of sufficient rumber and were of good depth and constituted good program assessment tools for management. The corporate office provided good support to the onsite radiation protection program through assistance in tecinical matters and performance based assessments. A high quality system of occurrence reporting was in use. The '

timeliness of the radiation protection department's response to quality notices had improved, but some responses still were made after the due dat New senior radiation protection technicians met qualification requirement The licensee promoted the professional development of radiation protection technician ,

Areas within the radiological controlled area were properly posted and ,

controlled. Radiation protection personnel provided excellent coverage for power entries into the containment buildin The ALARA program received strong support from management and workers. ALARA committee meetings were well attended by representatives of all groups, and

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the meeting provided for a free exchange of information among the members- '

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regarding dose saving measures. The ALARA suggestion program continued to show acceptance by the workers as a means of contributing dose saving idea The licensee's actual total exposure was below its goal for 1992 and was well below the national average for pressurized water reactor FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702) (Closed) Violation 382/9210-01: Use of Incorrect Radiation Work Permit t

The inspector determined that workers involved in the unloading of a transportation cask had mistakenly' signed and were working in accordance with a radiation work permit which was not intended for that particular phase of the wor The inspector reviewed lesson plans for radiation worker training and confirmed that lesson plans had been revised to included added emphasis on the-i

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. .i-8-importance of using the correct radiation work permit. Additionally, Procedure HP-001-101, "ALARA Program Implementation," was revised to require, when appropriate, a computer block be used to prevent workers from logging into the access control computer unless they had received the required prejob ,

briefing. The violation was also discussed with radiation protection personnel as part of their continuing technical training. The inspector reviewed radiation work packages requiring prejob briefings and did not identify additional problems. (See Section 2.1.)

4.2 (Closed) Violation 382/9221-01: Failure to Clearly Demarcate a Contaminated Area On a tour, the inspector identified a contaminated area whose boundary ropes were down, and the perimeter was not clearly indicate The inspector confirmed that this item was discussed in special meetings with the radiation protection technicians and that radiation protection management issued guidance on the proper techniques to use establishing barriers around contaminated area ONSITE REVIEW 0F LICENSEE EVENT REPORT (92700)

(Closed) Licensee Event Report 382/91-006: Hot Particle Contamination of Contract Technician

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The event involved a contract instruments and controls technician who caused the licensee's portal monitor to alarm upon entry of the protected are It was determined that the individual had become contaminated the previous day and undergone decontamination; however, a hot particle in one of the individual's shoes went undetected at the time and was released off sit The licensee calculated the dose to the skin to be approximately 648 millirems, and as such, did not constitute a violation of regulatory exposure limit The licensee determined that the root cause of the event was the failure of personnel monitors to detect a hot particle which was close to the detectio limit of the equipment. As corrective action, the licensee:

. Placed additional gamma sensitive portal monitors at the exits of the radiological, controlled area to supplement those at the exit of the protected are * Increased the frequency of sensitivity and response checks on the portal monitors during outages from daily to shiftl . Decreased the lower level of detection of the detectors. from 200 nanocuries to 100 nanocuries by increasing the counting tim ,

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The following procedures were revised to implement the changes: l

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e lip-002-480, " Calibration of the Eberline PM-7 Series-  :

Personnel Monitor," Revision 1 -

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e llP-002-371, " Instrument Source / Response Check," Revision 3 l

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ATTACHMENT  !

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-1 PERSONS CONTACTED l

1.1 Licensee Personnel j

• D. L. Hoel, Health Physics Supervisor  !

• T. J. Gaudet, Operational Licensing Supervisor i S. Ghanavati, Lead Senior Engineer, Reliability Engineering  !

B. L. Goldman, ALARA Coordinator i

• P. H. Kelly, Health Physics Supervisor ,

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• D. A. Landeche Lead Supervisor, Health Physics Support M. J. Langan, Technical Training Supervisor i

• T. R. Leonar,1, Technical Services Manager l

• T. P. Lett, Health Physics Supervisor 1

• D. F. Packer, General Manager, Plant Operations

• S. Ramsey, Senior Engineer, Health Physics 1.2 NRC Petsonnel i

• J. L. D:xon-Herrity, Reside +.t Inspector ~

• Denotes personnel that attended the exit meetin In addition to the personnel listed, the inspector contacted other personnel during this 1 inspection perio EXIT MEETING An exit meeting was condu: Led on January 29, 1993. During this meeting, the inspector reviewed the scope and findings of the report. The licensee did not identify as proprietary, any information provided to, or reviewed by the inspecto l l

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